Plunkett v. Plunkett

66 Va. Cir. 109, 2004 Va. Cir. LEXIS 327
CourtBotetourt County Circuit Court
DecidedOctober 13, 2004
DocketCase No. CH02000112-00
StatusPublished

This text of 66 Va. Cir. 109 (Plunkett v. Plunkett) is published on Counsel Stack Legal Research, covering Botetourt County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Plunkett v. Plunkett, 66 Va. Cir. 109, 2004 Va. Cir. LEXIS 327 (Va. Super. Ct. 2004).

Opinion

BY JUDGE MICHAEL S. IRVINE

This matter came to be heard on the 13 th day of August, 2004, upon the Bill of Complaint filed by the children of Carroll H. “Pete” Plunkett, deceased, asking this Court to impose a constructive trust on all “separate property of the decedent” in the possession, custody, or control of his widow, the defendant, and to order that such property be conveyed to the Plaintiffs outright, free of trust.

The issue presented to the Court is whether Pete Plunkett’s will, which leaves all of his marital and separate property to his wife Linda Plunkett, fails to conform to a post-nuptial agreement executed by Pete and Linda Plunkett by failing to devise Pete’s separate property to Pete’s children upon his death.

For the reasons hereinafter stated, the Court finds that the Plaintiffs have proven by clear and convincing evidence that the agreement provided for Plaintiffs to receive Pete Plunkett’s separate property under his will, and they are entitled to the relief sought.

The Plaintiffs argue for enforcement of the post-nuptial agreement between Pete Plunkett and his wife Linda Plunkett. Plaintiffs argue that the agreement provides that, upon the death of Pete Plunkett, his marital property should be devised to Linda Plunkett and that his separate property should be devised to his three children. Plaintiffs ask that a constructive trust be imposed [110]*110upon the separate property of Pete Plunkett to result in the transfer of the property to Pete’s three children.

Pete Plunkett and Linda Plunkett executed an agreement stating:

WHEREAS, the parties were married on February 20, 1990, and each of the parties have been married previously and that Pete has children by his previous marriage, and each owns substantial assets consisting of both real and/or personal property; and
1. Testamentary Disposition of Separate Estates. The parties each agree that in light of the fact that this was a second marriage for each of them, and that Pete has children from his previous marriage, that their separate property be devised and bequeathed to his children. Accordingly, the parties agree that they will execute the wills, copies of which are attached to this Agreement, and make no subsequent changes in testamentary disposition of their separate property to Pete’s children.

(Exhibit A, Agreement of August 17,1995.) Wills were executed along with the agreement. When Pete Plunkett died, his children received nothing under his will, which left all of his property, personal and marital, to his wife Linda Plunkett. Linda Plunkett argues that this is the result intended under the agreement, and she alleges that the agreement does not explicitly state that Pete’s children receive anything upon Pete’s death. She further argues that the agreement is fulfilled if, upon Linda Plunkett’s death, her will leaves the children all of the separate property of Linda and Pete Plunkett. Under this interpretation, the children are entitled to nothing under the agreement until both Linda Plunkett and Pete Plunkett are deceased.

The Plaintiffs, supported by additional language in the agreement, urge a different interpretation. The agreement goes on to state:

2. Testamentary Disposition of Marital Estate. The parties agree that they will execute the wills, copies of which are attached to this Agreement, and make no subsequent changes is [sic] testamentary disposition of their marital property in contravention to their intent to leave their marital property as set forth and described in this Agreement first to the survivor and then equally to all of the [sic] Pete’s children.

[111]*111(Exhibit A, Agreement of August 17,1995.) This clause addresses the marital property independent of the separate property, indicating that Pete and Linda Plunkett had some reason to address the two separately. Plaintiffs argue that the marital property is addressed independent of the separate property in the agreement because it was the intent of the agreement that the marital property go to the survivor of Pete and Linda Plunkett, but upon the death of Pete or Linda, the separate property was to go to Pete’s children. The questions to be decided are: what did the parties intend when they made the agreement? If Pete Plunkett’s will did not conform to the agreement, are Plaintiffs entitled to a remedy?

Findings

1. Plaintiffs Are Entitled to Enforce the Agreement

Two testators who enter into a contract to execute mutual and reciprocal wills are bound to bequeath their estates according to the terms of the agreement. Stephens v. Caruthers, 97 F. Supp. 2d 698, 703 (E.D. Va. 2000), citing Black v. Edwards, 248 Va. 90, 91-94 (1994). If the survivor fails to execute a will conforming to the agreement, the persons who would have benefited from a conforming will may sue to protect their interests. Stephens, 97 F. Supp. 2d at 703-04. In this case, it is not the survivor’s will that is alleged to be nonconforming, but the will of the non-surviving party to the agreement.

Of course, while both testators are still living, they may agree to change, modify, or revoke an agreement to execute mutual and reciprocal wills. But if there is no change, modification, or revocation by the testators, and one ofthem dies having performed, the other party’s final will and testament must conform to the agreement.

Stephens, 97 F. Supp. 2d at 704, citing Williams v. Williams, 96 S.E. at 751 (emphasis added). It is clear that the agreement is enforceable as to Linda Plunkett if Pete Plunkett dies having performed in accordance with the agreement. Here, however, it is not Linda Plunkett who is alleged to have breached the agreement, but Pete Plunkett himself because it is Pete’s will that Plaintiffs allege to be nonconforming to the agreement.

In this case, Pete Plunkett’s will is alleged to be nonconforming because of a drafting mistake, and not because of any subsequent changes made by [112]*112Pete. Accordingly, the plaintiffs are third-party beneficiaries to the agreement and. can enforce their rights against the surviving party.

2. Constructive Trust is the Proper Remedy

In Jones v. Harrison, 250 Va. 64, 69 (1995), the Supreme Court stated that equity will impose a constructive trust upon property in the hands of the recipient of property that is given or devised to a defendant in breach of a testator’s contract with a plaintiff, even if the transfer is not the result of fraud or wrongdoing on the part of the devisee. In this case, as discussed above, there is no alleged breach in a contract with the plaintiffs, but rather an alleged breach in an agreement made between the testator and the defendant. However, the agreement was made for the benefit of the plaintiffs. Plaintiffs should be afforded a remedy to protect their rights, if any, under the agreement. If Pete Plunkett’s will as executed is not in conformance with the agreement, the Court is authorized to enforce the agreement in equity by declaring Pete Plunkett’s separate property to be held in constructive trust for the plaintiffs.

■3. Plaintiffs Provide Clear and Convincing Evidence of Their Interpretation of the Agreement

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Related

Jones v. Harrison
458 S.E.2d 766 (Supreme Court of Virginia, 1995)
Black v. Edwards
445 S.E.2d 107 (Supreme Court of Virginia, 1994)
Blincoe v. Blincoe
163 S.E.2d 139 (Supreme Court of Virginia, 1968)
Stephens v. Caruthers
97 F. Supp. 2d 698 (E.D. Virginia, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
66 Va. Cir. 109, 2004 Va. Cir. LEXIS 327, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plunkett-v-plunkett-vaccbotetourt-2004.